Tax

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Argentine Supreme Court rules against Molinos in tax treaty abuse case
mnetax.com Sep 20, 2021
India proposes rules to implement farewell to the retro tax
mnetax.com Sep 16, 2021
India intercompany financing: debt versus equity and the pricing of intercompany loans
mnetax.com Sep 15, 2021
The Mumbai Income Tax Appellate Tribunal ruled against the Indian tax authority on August 20 in Bennett Coleman & Co Ltd (As successor to Times Infotainment Media Limited) v. Deputy Commissioner of Income Tax. The litigation involved two questions...
Asia to see disparate impacts from global digital tax reforms, IMF reports
mnetax.com Sep 15, 2021
India-US bilateral advance pricing agreements and tax benefits for US multinationals
mnetax.com Sep 15, 2021
Brazilian National Congress approves income tax reform preliminary text
mnetax.com Sep 14, 2021
The Brazilian National Congress approved on September 2 the preliminary text of the income tax reform (bill 2,337), which includes important changes from the original draft presented June 25. According to the approved text, the corporate income tax...
Cyprus to introduce transfer pricing legislation
mnetax.com Sep 14, 2021
New legislation on transfer pricing was submitted to the Cyprus parliament in June with an aim to comply with action points 8–10 of the OECD base erosion profit shifting (BEPS) plan. The proposed legislation defines the persons obliged to maintain...
US Senate bill would amend pass-through rules to address corporate tax abuse
mnetax.com Sep 10, 2021
Senate Finance Committee Senator Ron Wyden (D-Ore.) released a discussion draft on September 10 for legislation that would tighten rules around partnerships and other pass-through entities to prevent large corporations and wealthy investors from...
Polish Deal introduces new minimum tax for corporations
mnetax.com Sep 10, 2021
On 8 September, Poland’s government accepted a new tax bill called the “Polish Deal,” announcing after the public consultation on the bill a significant amendment to include a special anti-avoidance measure referred to as a minimum income tax for...
Yellen assures G7 that US tax reform is on track, still shooting for 21% GILTI rate
mnetax.com Sep 9, 2021
In a September 9 virtual meeting, US Treasury Secretary Janet Yellen told the G7 finance ministers that the Biden Administration is “pleased with the progress the U.S. Congress is making” on moving the President’s proposed US international tax...
Corporate tax rates down 10 percentage points among OECD, G20, EU countries
mnetax.com Sep 9, 2021
The combined statutory corporate income tax rates among OECD, G20, and EU countries dropped in parallel from 2000–2021, 10 percentage points in each group, while broadly maintaining their positions relative to each other, according to a September 8...
Two minimum taxes: US eyes robust rate, while small countries seek carve-outs
mnetax.com Sep 8, 2021
The US should raise the minimum tax on corporate foreign earnings to 21% while the OECD works towards a 15% floor on tax competition, according to a September 7 article from two US Treasury officials. Similar calls were made by a group of...
US R&D tax incentives will be among least generous unless Congress acts, study finds
mnetax.com Sep 8, 2021
The US will drop to a rank of 32nd among a peer group of 34 large economies in terms of its tax support for research and development (R&D) if it allows the new requirement to amortize R&D expense to take effect as scheduled in 2022, according to a...
European banks’ tax haven use persists but varies widely, study finds
mnetax.com Sep 7, 2021
Large European banks report an average of 20% of their profits in tax havens, but the percentages vary significantly, with some reporting more than half of their profits in such jurisdictions while others report none, according to a September 6...
Dutch intercompany financing rulings and the transfer pricing of intercompany loans
mnetax.com Sep 2, 2021
The Dutch tax authorities often challenge intercompany debt by claiming the financing should be considered equity. A July 16 Supreme Court decision in ECLI:NL:2021:1152 ruled in favor of the tax authority using the doctrine of fraudem legis...
India announces rules for book profits tax relief related to APAs, secondary adjustments
mnetax.com Sep 1, 2021
The Indian tax administration on 10 August issued rules for computing relief related to the tax on book profits in cases where there was an increase in book profits of a particular financial year on account of an advance pricing agreement (APA) or...
US congressional research papers prepare lawmakers for international tax debate
mnetax.com Aug 30, 2021
The US Congressional Research Service on August 26–27 published three reports addressing the status of corporate and international tax legislation and reform in anticipation of upcoming debates on corporate tax rates, international tax provisions,...
Vietnam’s new transfer pricing APA regulations – some hurdles but still promising
mnetax.com Aug 30, 2021
New detailed guidance from Vietnam’s Ministry of Finance on the advance pricing agreement (APA) program came into effect on 3 August, introducing both some new challenges and some welcome developments. The guidance, which was issued 18 June in...
US Senate unveils international tax reform draft legislation
mnetax.com Aug 25, 2021
Senate Finance Committee Chairman Ron Wyden (D-Ore.) on August 25 released draft legislation for international tax reform that would retain but modify – and, partly, rename – key provisions of the Republicans’ 2017 tax law, including the global...
Global minimum tax’s ‘GloBE’ maze – more than meets the eye!
mnetax.com Aug 25, 2021
The past two months have witnessed historic international tax cooperation with 133 jurisdictions agreeing to implement the two-pillar solution set forth in the 1 July OECD/G20 Inclusive Framework statement. As the statement manifests, the tax world...
Poland corporate tax bill clarifies definition of place of management
mnetax.com Aug 24, 2021
On 28 June, Poland’s Ministry of Finance launched a public consultation for a new tax bill called the “Polish Deal.” According to the Ministry, the proposed amendments to the corporate income tax law should help in creating a level playing field...
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